PROCEA2500030 016 - Redacted Consolidation Determination FFEO Support Contract.pdf

This is a Determination and Findings (D&F) document justifying the consolidation of multiple existing contracts into a single indefinite-delivery, indefinite-quantity (IDIQ) contract for the EPA's Federal Facilities Enforcement Office (FFEO). The EPA proposes to consolidate six existing task orders and call orders currently awarded to large businesses under a multiple-award IDIQ contract with a five-year ordering period for firm-fixed-price and cost-plus-fixed-fee task orders. The consolidation threshold exceeds $2,000,000, requiring justification under FAR 7.107-2 and EPA Acquisition Policy (EPAAP) 7.1.2.

The current fragmented approach involves support from two different contracting divisions and at least three Contracting Officer's Representatives (CORs), creating administrative burden and inefficiency. Market research identified only five vendors with required EPA-credentialed inspectors in the marketplace, with only two capable vendors (both large businesses) known to have EPA credentials. The Sources Sought synopsis issued June 23, 2025, with a closing date of July 8, 2025, generated fourteen responses from four large businesses and ten small businesses, though none of the small businesses possessed EPA-credentialed inspectors. The D&F determines consolidation is necessary and justified based on anticipated benefits including quality improvements, reduced acquisition lead-times, streamlined contract management, conflict-of-interest mitigation, and projected administrative cost savings of 10-20 percent. The consolidated requirement will be solicited on a full and open competitive basis.